The Sandra Day O'Connor U.S. Courthouse in Phoenix
Photo: Tony Webster via Wikimedia Commons (CC BY 2.0)
Phoenix

Phoenix Judge Dismisses USDA Lawsuit, Bars Plaintiff From Using AI on Amended Complaint

U.S. District Judge Krissa Lanham ruled the 67-page complaint "appears to have been generated by artificial intelligence" and called it an improper shotgun pleading. The self-represented plaintiff was ordered to write any amended complaint herself.

The Short Version

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A federal judge in Phoenix has tossed out an employment discrimination lawsuit against the U.S. Department of Agriculture — not on the merits of the claims, but because the complaint itself, the judge said, bears the unmistakable fingerprints of a chatbot. In a ruling issued Wednesday, U.S. District Judge Krissa Lanham found that the 67-page complaint "appears to have been generated by artificial intelligence ('AI') as it resembles other AI-generated complaints the court has encountered," Reuters reported. She called the filing an improper "shotgun pleading" whose sprawling, repetitive allegations were poorly connected to unclear legal claims — and then took the unusual step of ordering the plaintiff to draft any amended complaint by hand, without AI.

The ruling67 pages the judge says a machine wrote

Plaintiff Shelly George sued the USDA in September, alleging the agency illegally retaliated against her and subjected her to a hostile work environment, according to Reuters. But Lanham wrote that the complaint's factual allegations were voluminous, difficult to follow, repetitive, and did not appear necessary — the classic hallmarks, in the court's experience, of a document assembled by generative AI rather than a person, Reuters reported.

Another view of the Sandra Day O'Connor U.S. Courthouse in Phoenix
The Sandra Day O'Connor U.S. Courthouse in Phoenix, where the case was filed. Photo: Tony Webster via Wikimedia Commons (CC BY-SA 2.0)

The order then went further than most judges have. Lanham barred George — who is representing herself — from using AI to draft the amended complaint. "George must personally draft the allegations she believes relevant to her claims and identify the claims she wishes to pursue," the judge wrote, as reported by Reuters. She also required both sides to disclose any use of AI and to confirm that AI-generated outputs had been verified.

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The fine printWhat the judge did — and did not — bar

Precision matters in this story, because the ruling is narrower than the headline might suggest. Lanham barred AI specifically from drafting the amended complaint — the document George would need to file to revive her claims. She did not bar the use of AI in all future filings in the case, Reuters reported. Nor did she shut the door on the case itself: George was granted the chance to amend and refile, this time writing the allegations herself and identifying exactly which claims she wants to pursue.

The term the judge used — "shotgun pleading" — is one courts deploy for complaints that fail federal court basics: a complaint must contain a short, plain statement of the claims, with facts tied to specific legal theories. In federal practice, a shotgun complaint is one that buries its claims under lengthy, disorganized allegations that cannot be adequately answered — a defect judges treat as an independent ground for dismissal, even apart from whether the underlying claims might have merit. In other words, the ruling says nothing about whether George's underlying discrimination claims have merit. It says the complaint, as written, could not be litigated.

A wooden gavel in a museum collection
A gavel. Judges are increasingly sanctioning filings that appear to contain AI-generated errors or incoherent allegations. Auckland Museum via Wikimedia Commons (CC BY 4.0)

The responseThe plaintiff plans to amend and refile

George told Reuters she plans to amend her complaint and refile the lawsuit. She pushed back on the ruling's premise: she told Reuters she found no law limiting the number of pages in a case filing, that AI was only partially used, and that she did not understand the dismissal if the language in the complaint was valid. Neither the judge nor the Agriculture Department immediately responded to Reuters' requests for comment. The ruling was issued Wednesday, Oct. 7, and reported by Reuters on Oct. 9 — and the order leaves George a clear path back into court, as long as the next version of the complaint is written in her own words and states plainly which claims she wants to pursue.

The case behind itGeorge v. Rollins, filed Sept. 11

Court records corroborate the case's contours. Justia's federal dockets database lists the matter as George v. Rollins, No. 3:2026cv08218, filed September 11, 2026, in the U.S. District Court for the District of Arizona. The plaintiff is Shelly George and the defendant is Brooke L. Rollins — the Secretary of Agriculture, sued in her official capacity. The cause of action is listed as 42 U.S.C. § 2000e, job discrimination (employment) — the federal employment-discrimination statute.

The bigger pictureCourts are cracking down on AI filings

The Phoenix ruling is part of a growing wave, Reuters reported. Litigants and lawyers are generally allowed to use AI for legal research and drafting, so long as they verify their work — but judges are increasingly encountering court filings with apparent AI-generated errors or incoherent allegations, and increasingly sanctioning them, particularly from self-represented parties. In a different pending case in Florida, Reuters noted, an appeals court is weighing sanctions against a lawyer over what it called AI-generated "slop" in court filings — filings a panel described as excessively long, unfocused and sometimes gibberish. Some judges have begun requiring parties to disclose AI use; others have imposed outright bans on the technology in preparing filings, Reuters reported. Arizona courts are now firmly on the map. For more Phoenix legal news, see our coverage of the Lauren Heike case here, and the Arizona AG's TikTok lawsuit here.

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